In a past post, we talked about how agencies need to ask for more VPATs. But what do you do with a VPAT once you have it? Just because a company has created a VPAT, doesn’t mean that the product or service fully conforms to all Section 508 requirements. Here are some thing to watch out for:
- First read the VPAT! It may tell you that even the vendor thinks that they do not meet some Section 508 provisions.
- Check to see if all the provisions the vendor marked as applicable match what your agency thinks is applicable. For example, did they discuss Functional and Information, Documentation, and Support provisions?
Note: Buy Accessible Wizard or Quick Links can help you determine applicable provisions for your product or service requirements.
- Check the version number. Does the VPAT cover the version of the product you are buying? Upgrades may have increased or decreased the accessibility of the product.
- Verify that if the vendor says that they meet a provision that they actually do. This takes a little more time and means you need to conduct acceptance testing of the product.
Do you have any comments or suggestions you would like to share about how to use and read VPATs?
Past Section 508 blog posts about VPATs.
This time of year, many government acquisitions professionals are rushing to do procurements. Did you know about the Quick Links that provide quick and easy pre-packaged Section 508 solicitation documentation for a number of standard EIT deliverables? In addition to providing solicitation documentation, these links identify typical applicable Section 508 provisions to help agencies in generating Government Product/Service Accessibility Templates (GPATs) and vendors responding with Voluntary Product Accessibility Templates (VPATs).
In your rush, don’t forget that any attachments you include in your solicitation need to be accessible. A document scanned to PDF isn’t accessible unless you make it so!
There is a misconception that Voluntary Product Accessibility Templates (VPAT) are a problem because they are always voluntary. It is true that a company can decide to voluntarily create a VPAT and post it on their website. BUT, if a government agency requires a VPAT as part of their solicitation, then it is no longer voluntary. It becomes a requirement. The only voluntary part is whether or not the company wants to compete for that contract. If a government agency is procuring Electronic and Information Technology (EIT), then it is their responsibility to require accessibility information be provided by the bidder.
Here are some past blog posts about the VPAT and some more about Common Misconceptions.
Government buyers can now use the Accessibility Resource Center to find accessibility information on the product or service they intended to buy. The Accessibility Resource Center contains an alphabetic list of many company websites with links to their product and service accessibility information, including VPATs when available. Many of these companies participate in the BuyAccessible Product and Services Directory, but we find there is often more up to date information on their websites.
Accessibility Resource Center is also integrated into the BuyAccessible Wizard’s market research section. Wizard users can use Accessibility Resource Center to conduct their market research and document the results in the Wizard.
Government buyers, if you do not find what you are looking for, please refer to GSA Section 508 guidance document on conducting accessibility market research. You can also ask vendor s to provide you with a Voluntary Product Accessibility Template (VPAT) for the product in your solicitation. (Here are some more posts about VPATs.)
Vendors, if you have accessibility information on the internet and are not on this list, you are welcome to please send us your information to include in our next release.
The websites listed in the Accessibility Resource Center have been found using internet searches and were not necessarily given to us by the vendor themselves. We do not guarantee that all URLs are working or up to date.
If you have used the ARC and have any comments about it, please let us know.
Recently we heard a question on how a vendor could provide information on the fact that making their product fully Section 508 accessible would require a fundamental alteration. Section 508 1194.3 (e) states that an exception to the Section 508 rule is that the part shall not be constructed to require a fundamental alteration in the nature of a product or its components.
Ultimately it is the agency’s responsibility to claim exceptions, not the vendor’s. The agency will use information from the vendor to make that assessment.
The answer to the question above is that the Vendor Product Accessibility Template (VPAT) does not have a place to write about Section 508 exceptions. The vendor could make a comment under the “Remarks and Explanations” column about how certain aspects of their product don’t conform and that making changes would require a fundamental change to the product or its components.
The biggest problem with buying accessible electronic and information technology in the Federal government isn’t bad VPATs (or other 508 conformance documentation); it is the fact that we don’t even ask most of the time! As part of GSA’s sampling of Fed Biz Opps solicitations, we check to see if agencies request a VPAT from vendors when they are trying to procure EIT. In our sampling, we found that only 6% of the time do agencies ask for a VPAT.
The fix? Use BuyAccessible.gov and get the right language for your solicitation, and you can require your offerors to fill out and submit the Government Product/Services Accessibility Template (GPAT).
To learn more about the difference between a VPAT and GPAT read this past post.
We just added 12 more Quick Links to Buyaccessible.gov to bring the total to 29! There is a whole new interface called the Quick Links Resource Center to help you quickly find pre-packaged Section 508 documentation for some standard EIT deliverables.
On the home page you can select an EIT deliverable (i.e. a product or service), then say if you are a buyer, micropurchaser, or seller.
- Buyers’ Quick Links include solicitation language.
- Buyers and Micropurchasers’ Quick Links include a GPAT to help communicate applicable Section 508 requirements to vendors.
- Vendors’ Quick Links include a GPAT to help them create their own VPAT to let the government know how well their product or service meets Section 508 requirements.
There is also a glossary that defines the types of EIT deliverables in Quick Links. If you can’t find your deliverable in the home page list, then you can search the glossary to check if it is listed under another name.
If you are doing development or maintenance, you can also use the GPAT in the Quick Link to discover what Section 508 provisions may apply.
Please let us know how well it works for you and send us any suggestions by submitting a comment on this blog or through the Quick Links “Contact Us” link.
The answer is that they are similar, but not the same. The Government Product/Services Accessibility Template (GPAT) reflects the government agency’s accessibility requirements for the type of EIT they intend to buy. The Voluntary Product Accessibility Template (VPAT) reflects the accessibility features of the vendor’s product. Requirements may or may not match features. Features may or may not match requirements. The implication for an agency is that you have to assess all accessibility features of a product and not just those you have specified. The implication for a vendor is that you have to document all the accessibility features of your product and not just those identified by the agency.
Section 508 certification doesn’t exist. Voluntary Product Accessibility Templates (VPAT) are the best way for vendors to provide accessibility information to the government.
Some people are claiming that they can provide vendors with a third party certification that their products are Section 508 compliant. Well that simply isn’t possible! No one, including the agency buying the product or service, can certify compliance or conformance, because there are no accepted tests. In the end the federal agency purchasing a product or service is responsible for determining if the deliverables meet their requirements.
Vendors can give the government information about the accessibility features of their products and services in the form of a (VPAT). The government looks at VPATs during their market research, and may even require vendors to provide VPATs or a Government Product/Service Accessibility Template (GPAT) for a proposal or with deliverables.
That being said, there are a lot of experienced companies who can help vendors prepare VPATs or GPATs. Many companies also offer expert services to federal agencies to assist in determining how well products and/or services conform to the Standard.